Tag Archives: Principal Commissioner of Income-tax

Supreme Court dismisses Revenue’s SLP, upholding disallowance of bogus purchases restricted to six percent.

By | September 25, 2026
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Supreme Court dismisses Revenue’s SLP, upholding disallowance of bogus purchases restricted to six percent. Supreme Court dismisses Revenue’s SLP, upholding disallowance of bogus purchases restricted to six percent. Issue Whether the Special Leave Petition (SLP) filed by the Revenue should be entertained against the High Court’s order upholding the Tribunal’s decision to restrict the disallowance… Read More »

Disallowance for Bogus Purchases from Bhanwarlal Jain Group Correctly Restricted to 6 Percent

By | September 23, 2026
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Disallowance for Bogus Purchases from Bhanwarlal Jain Group Correctly Restricted to 6 Percent Issue Whether any substantial question of law arises against the Tribunal’s decision restricting the addition for bogus purchases from the Bhanwarlal Jain Group to 6 percent of the total non-genuine purchases. Facts Context & Period: The matter pertains to Assessment Years 2007-08… Read More »

Deduction for ESOP expenses and CA-certified share valuation for Section 56(2)(viib) are legally allowable.

By | September 22, 2026
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Deduction for ESOP expenses and CA-certified share valuation for Section 56(2)(viib) are legally allowable. Issue Whether deduction for Employee Stock Option Scheme (ESOP) expenditure is allowable as business expenditure, and whether a share valuation report from a Chartered Accountant under Section 56(2)(viib) for AY 2018-19 can be rejected solely on the ground that it was… Read More »

SLP Dismissed as Vague Show Cause Notice Lacking Specific Grounds Cannot Sustain Section 271(1)(c) Penalty

By | September 21, 2026
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SLP Dismissed as Vague Show Cause Notice Lacking Specific Grounds Cannot Sustain Section 271(1)(c) Penalty SLP Dismissed as Vague Show Cause Notice Lacking Specific Grounds Cannot Sustain Section 271(1)(c) Penalty Issue Whether a penalty under section 271(1)(c) can be sustained when the show cause notice issued by the Assessing Officer is vague due to non-striking… Read More »

Firm’s Property Auction and Tax Recovery Valid within Limitation, Meeting All Statutory Requirements

By | September 19, 2026
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Firm’s Property Auction and Tax Recovery Valid within Limitation, Meeting All Statutory Requirements Issue Whether tax recovery proceedings and the auction sale of a defaulting firm’s properties were barred by limitation under Rule 68B of the Second Schedule to the Income-tax Act. Whether the non-service of individual notices to each partner vitiated the recovery proceedings… Read More »

Non-Speaking Tribunal Order with Procedural Irregularities Quashed and Remanded for Fresh Adjudication

By | September 19, 2026
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Non-Speaking Tribunal Order with Procedural Irregularities Quashed and Remanded for Fresh Adjudication Issue Whether a common order of the Tribunal vitiated by complete non-application of mind, total absence of reasoning, and serious procedural irregularities (including conflicting hearing and pronouncement dates) is liable to be quashed and remanded for fresh adjudication. Facts Section 153C Proceedings: The… Read More »

Inordinate Delay of 1480 Days Without Sufficient Cause Refused; High Court Appeal Dismissed as Time-Barred

By | September 18, 2026
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Inordinate Delay of 1480 Days Without Sufficient Cause Refused; High Court Appeal Dismissed as Time-Barred Inordinate Delay of 1480 Days Without Sufficient Cause Refused; High Court Appeal Dismissed as Time-Barred Issue Whether an inordinate delay of 1480 days in filing an appeal under Section 260A by the Revenue department can be condoned, even after extending… Read More »

Second reassessment notice under Section 148 for income already assessed and taxed is illegal and invalid

By | September 17, 2026
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Second reassessment notice under Section 148 for income already assessed and taxed is illegal and invalid Issue Whether an Assessing Officer (AO) can legally issue a second notice under Section 148 of the Income-tax Act, 1961 (corresponding to Section 280 of the Income-tax Act, 2025) for a transaction that has already been assessed and brought… Read More »

Unsupported Presumptions and Lack of Evidence Cannot Disallow Section 80-IE Deduction or Reallocate Ordinary Profits

By | September 15, 2026
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Unsupported Presumptions and Lack of Evidence Cannot Disallow Section 80-IE Deduction or Reallocate Ordinary Profits Issue Whether an assessee-firm is entitled to Section 80-IE deduction when concurrent findings confirm old machinery did not exceed 20%, and whether the AO can arbitrarily reduce eligible profits by allocating royalty, management fees, and R&D expenses under Section 80-IA(10)… Read More »

Reassessment Notice Based on Mere Change of Opinion Already Examined in Scrutiny Is Invalid

By | September 15, 2026
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Reassessment Notice Based on Mere Change of Opinion Already Examined in Scrutiny Is Invalid Reassessment Notice Based on Mere Change of Opinion Already Examined in Scrutiny Is Invalid Issue Whether an assessment reopened under Section 148 of the Income-tax Act, 1961 is legally permissible when the specific transaction relied upon for reopening was already thoroughly… Read More »